The FAA on July 10 released the final rule for the Pilot Certification and Qualification Requirements for Air Carrier Operations, which will require pilots to hold an air transport pilot certificate in order to fly for an air carrier.

AOPA expressed its concern in the original notice of proposed rulemaking (NPRM) on the effect the rule will have on Part 61 flight training providers and new student pilot starts. AOPA’s concerns were also expressed in the proceedings leading up to the final rule, scheduled to go into effect on Aug. 1, by commenting on both the advance notice of proposed rulemaking and notice of proposed rulemaking, released on Feb. 29, 2012, and participating in the First Officer Qualifications Aviation Rulemaking Committee.

Pilots applying for an air transport pilot (ATP) certificate and those intending to serve as first officers for airlines will be the ones most affected by the new rule. But it will also affect pilots wanting to serve as pilot in command in Part 121 air carrier operations, part 91 subpart K operations, or Part 135 operations because of changes to requirements for obtaining an ATP certificate.

Pilots pursuing an ATP certificate after July 31, 2014, in addition to having 1,500 hours, will have to complete a new, yet-to-be developed, ATP certification training program. The program, consisting of 30 hours of ground and 10 hours of simulator training, must be completed prior to being eligible to take the ATP written and practical tests. The 10 hours of simulator training will include six hours of training in a level C or D (full-motion) simulator. According to the rule, this course will only be offered through Part 141, 142, 135, or 121 certificate holders, not allowing for Part 61 flights schools to develop courses and provide the training.

The new rule also establishes a new ATP certificate with restricted privileges for multiengine airplane only. The restricted ATP certificate can only be used to serve as a first officer at an air carrier. To obtain that certificate an applicant must be at least 21 years old, hold a commercial pilot certificate with an instrument rating, complete an ATP certification training program, and pass the ATP written and knowledge tests. For the restricted ATP certificate, applicants do get some relief as they are required to have at least 750 hours total time as a military pilot; at least 1,000 hours total time and a bachelor’s degree with an aviation major; at least 1,250 hours total time and an associate’s degree with an aviation major; or 1,500 hours total time as pilot.

“Although seemingly primarily directed at air carriers, AOPA had significant concerns with the NPRM about the effect this rule will have on Part 61 flight training providers and new student pilot starts,” said AOPA Vice President of Regulatory Affairs Rob Hackman. “The final rule will effectively prevent Part 61 training providers from being a viable pathway to an airline carrier both by limitation on who can provide the required training and on how time is credited toward the restricted ATP certificate. On first read, it appears the final rule does little to address AOPA’s concerns. As it stands, it has the potential to negatively affect flight training by disenfranchising potential career pilots thus negatively effecting flight schools.”

For further details, read AOPA's briefing paper on the final rule for pilot certification and qualification requirements for air carrier operations.